Object

Representation ID: 9638

Received: 29/07/2022

Respondent: Arnold White Estates Ltd

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

AWG supports the principle of significant growth being directed to the south of Bedford
along the A421 Corridor and at its land at Kempston Hardwick. The area is well-located
for access to the strategic highway network, including the junction of the A421 with the
A428, approximately 2.5 miles south of Bedford town centre. The A421 is the main
thoroughfare connecting Bedford with the M1 and A1 and is the route where significant
investment is proposed. The area benefits from existing rail links, with the Kempston
Hardwick railway station located centrally in the parties’ site on the Bedford to
Bletchley line providing services into Bedford Town Centre, Bletchley, and Milton
Keynes roughly every 30 minutes in each direction. There are also regular bus services
on the B530 and in Stewartby to the south which provide public transport links into
Bedford and nearby settlements. The area’s connectivity is set to improve further as a
result of the proposed improvements to the East West rail line which would connect the
communities between Oxford, Milton Keynes, Bedford, and Cambridge. These national
investments in infrastructure improvements are part of the wider growth strategy for
the Oxford-Cambridge Arc aimed at unlocking the full economic potential of the region.
2.2 On this basis, the area to the south of Bedford, around Kempston Hardwick, has huge
potential and is very clearly the right location for new development of significant scale.
2.3 As set out in detail in the representations by Cloud Wing, AWG’s’ view is that the Plan
significantly underestimates the amount of employment land required in the Borough
to meet its needs and reflect the wider economic ambitions the region. On this basis,
Policies DS2(S) and DS5(S), and the Development Strategy Options Paper and
Sustainability Appraisal (‘SA’) evidence on which they are based, only seek to deliver the
scale of employment growth identified in Policy DS4(S). The policies are not, therefore,
considered sound (i.e. are not positively prepared, justified, effective or consistent with
national policy). Overall, Policy DS5(S) fails to identify sufficient employment land,
including to the South of Bedford at Kempston Hardwick, to meet anticipated economic
and employment needs over the plan period in accordance with paragraph 82 of the
NPPF.
2.4 National Policy therefore provides a clear, positive context with a clear requirement to
meet identified needs in an aspirational but deliverable fashion. Importantly, the NPPF
does not state that Plans should adopt a ‘do minimum’ approach; instead it promotes
ambitious growth, where it is carried out in a sustainable fashion.
Employment Needs
2.5 The evidence underpinning these policies has failed to consider all reasonable
alternatives, including a larger amount of employment land. The SA’s assessment of the
employment land options is flawed. It considers three options: C) 90Ha (more highdensity
office development); D) 142Ha; and E) 206Ha (lower density office/ business
park dev with more warehousing). These options do not appear to be consistent with
those presented in the Employment Land Study 2022. In addition, the SA concludes that
‘Option E’ (i.e. the option delivering the most employment) is worst performing
including in terms of ‘improving air quality’, ‘reducing carbon dioxide’, ‘improving
5 Pre-Submission Local Plan Consultation Response ● APL–251
energy efficiency’, ‘reducing the need to travel and promote sustainable modes of
travel’.
2.6 The SA appears to have reached this conclusion on the basis that this option would
result in greater increase in private car use and commercial vehicle use than other
options with less warehousing. However, this assessment is overly simplistic and fails to
consider that the Council’s strategy of relying on neighbouring authorities to meet
strategic warehousing needs could result in promotion of less sustainable commuting
patterns and freight movements than would be the case than if those needs were met
locally within close proximity to the existing and proposed population in Bedford. It also
fails to recognise the strategic importance of logistics as critical infrastructure
nationally, regionally, and locally or the Government’s ambitions to achieve a net zero
freight sector by 2050.
2.7 Option E also scores more poorly than Option D against the objective of promoting a
strong, sustainable, and balanced economic growth stimulating job creation across a
range of sectors. It is not clear why this is the case; the SA simply suggests that low
density office development with greater proportion of warehousing “uncertain whether
this will be viable locally”. The market evidence above clearly demonstrates that
warehousing is viable in this location.
2.8 The Development Strategy Options Paper (‘DSO’) and SA also consider a range of
strategy options as ‘reasonable alternatives’. The SA notes that for the purpose of
identifying ‘reasonable alternatives’ the aim is to consider options that could meet the
dwelling and employment requirement to 2040. However, it later goes on to state that
the employment requirement is not considered an overriding constraint in generating
options. Indeed, it is acknowledged in the DSO that most of the ‘reasonable
alternatives’ identified would fail to achieve the amount of employment land
contemplated in the Plan without additional sites being identified along the A421
corridor. Overall, whilst we agree with and support the identification of the area around
Kempston Hardwick as a location for significant growth, AWG is concerned that the
approach to the distribution of other employment land in the Borough is not
appropriately justified.
2.9 AWG is also concerned that the approach taken means that the opportunity presented
by a larger Business Park, incorporating a mix of employment uses, on AWG land to the
South of Bedford as part of the overall spatial strategy and distribution of employment
growth, has not been appropriately considered or assessed as a ‘reasonable alternative’
as part of the Council’s Local Plan evidence base. This approach risks missing a major
opportunity for economic growth on a transformative scale that is well-located to
benefit from improved rail connectivity.
2.10 More generally, the Council’s approach to the assessment of and selection of ‘other
employment sites’, particularly those along the A421 Corridor, is not clear or
transparent. Para 5.18 of the DSO states that other potential employment locations
“have been assessed according to their accessibility, visibility and proximity to strategic
transport routes, and their compatibility with neighbouring uses”. However, there does
not appear to be any evidence of this in the evidence provided beyond the general site
assessment proforma in the appendices to the HELAA and no explanation on how
judgements have been reached about particular sites.
2.11 AWG remains concerned that the Council’s proposed spatial strategy results in a
‘piecemeal’ approach to employment development elsewhere across Borough, and an
6 Pre-Submission Local Plan Consultation Response ● APL–251
over-reliance on ‘innovation’ uses to deliver its economic needs. This approach would
result in a number of individual developments without the critical mass to generate the
level of investment required to facilitate the infrastructure needed and deliver
sustainable economic development. It is also unlikely that innovation uses would be
able to generate the significant uplifts in land value that major industrial and logistics
schemes generate and that are often needed to fund strategic infrastructure
requirements (e.g. new and improved junctions on the strategic road network and link
roads).
2.12 A piecemeal approach to employment development across Bedford and over-reliance
on innovation uses would result in individual developments each without the critical
mass and market conditions to generate the level of investment required to facilitate
the infrastructure needed to support the scale of development anticipated and deliver
sustainable economic development.
Housing Needs
2.13 Paragraph 15 of the NPPF (2021) requires Local Plans to, inter alia, provide a framework
for addressing housing needs and other economic, social, and environmental priorities.
2.14 Paragraph 16 states that Local Plans should be prepared with the objective of
contributing to sustainable development and be prepared positively in a manner that is
aspirational as well as deliverable.
2.15 The NPPF also requires (para 23) that the Strategic Policies of the Plan should provide a
clear strategy for bringing land forward to meet objectively assessed needs in line with
the presumption in favour of sustainable development (para 11), and, in doing so,
allocating sufficient sites to deliver the strategic priorities of the area.
2.16 National Policy therefore provides a clear, positive context with a clear requirement to
meet identified needs in an aspirational but deliverable fashion. Importantly, the NPPF
does not state that Plans should adopt a ‘do minimum’ approach; instead it promotes
ambitious growth, where it is carried out in a sustainable fashion.
2.17 Bedford Borough sits in a key location within a national area of strategic importance,
being at the heart of the Oxford-Cambridge Arc (‘the Arc’). Whilst the timetable for the
Local Plan does not align with that of the Arc Spatial Framework, our client supports the
approach being taken by BBC of progressing the Local Plan in advance of the Arc Spatial
Framework and consider it is crucial that the Plan is adopted in a timely fashion.
2.18 The Local Plan 2030 was adopted on the basis of an early review and was examined
against the 2012 NPPF under transitional arrangements. The Local Plan 2030, therefore,
whilst being relatively “young” in Local Plan terms, is quite outdated in terms of its
approach to housing needs. The level of growth identified and allocated in the Local
Plan was based upon historic methods for identifying housing need, and, therefore,
suppresses housing need for a recently adopted Plan.
2.19 The Local Plan 2040 must, therefore, address this issue in addition to considering
housing needs associated with the Arc.
2.20 The Standard Method requirement (para 4.7 of the Local Plan) meanwhile, finds the
Borough’s housing need to be 1,355dpa, which the Local Plan applies across the plan
period of 2020 to 2040, creating a total of 27,100 dwellings.
7 Pre-Submission Local Plan Consultation Response ● APL–251
2.21 The Local Plan 2030 did not, therefore, meet the housing needs as now identified based
on the Standard Method. The Inspector’s Report into the 2030 Local Plan recognised (IR
para 40) that if the Standard Method had been applied in that instance, then the
housing need figure of 1,280dpa would have applied.
2.22 The Local Plan then proposes a stepped trajectory approach to deal with housing need,
with only 970 homes per annum in 2020-2025, and 1,050 between 2025-2030. There
would then be a significant increase to 1,700dpa in the final 10 years of the Plan.
2.23 The justification for this approach is due to the over reliance upon strategic allocations
which large infrastructure requirements.
2.24 This is not considered a sound approach and is effectively putting all the Council’s ‘eggs
in one basket’. It is not justified by the evidence and the Local Plan.
2.25 In particular, the Sustainability Appraisal testing of the ‘stepped approach’ is
fundamentally flawed, with the justifications given for positive scores around items such
as previously developed land (see SA Appendix 8 p. 113) being conjecture. The
statement that the stepped approach would have a more beneficial effect on
development on previously developed land is incorrect; sites which are previously
developed land can come forward irrespective of the stepped approach and the SA does
not identify any previously developed land south of Bedford that benefits from the new
rail stations and links. Indeed, the allocations at locations such as the Wixams are not on
previously developed land but greenfield land. The SA must, therefore, be re-run with a
correct assessment of the stepped approach.
2.26 A correct assessment of the stepped approach in the SA would identify that there are
risks with being reliant upon so much growth linked to strategic infrastructure outside
of the control of developers and the Council. This would in turn mean that many of the
benefits may not be realised, or realised later in the plan period, pushing housing
delivery outside of the plan period.
2.27 This is particularly evident in this area, with the still awaited deliver of the Wixams rail
station. That station was due to be completed in 2015 and is now timetabled for
opening in 2024.
2.28 Instead, the Plan should take a more balanced approach, with a reduction in numbers
on some of the strategic sites and the delivery of smaller strategic allocations which can
come forward earlier and increase housing delivery in the period to 2030.
2.29 The Local Plan is not sound, as it is not justified or effective. To make the Plan sound the
trajectory should be amended. Reflecting the fact that the Local Plan may not be
adopted until 2023, and thus higher delivery in 2024 (compared to the Local Plan 2030),
the trajectory should be as follows:
2020/21- 2023/24: 970dpa
2024/25 – 2039/40: 1,423dpa
2.30 Aligned with this, new allocations will be required, and a reduction in the number of
dwellings on some strategic sites may be required. These matters are dealt with below.